Last updated: 04.07.2022

This Privacy Policy is used by AEV Charging INC of undertakings, whereby AEV Charging INC (company registered in the US, File Number 5927623) is the controller of personal information, unless otherwise stated in your dealings with AEV Charging INC.

In this Privacy Policy we inform you about how we process your personal information, when offering charging solutions for electric vehicles (EV) and/or having other interactions with you, as explained in detail below.

• What personal information we process, why and on what legal basis;
• Who we are sharing your personal information with;
• To which countries your personal information might be transferred;
• For how long we keep your personal information;
• What rights you have concerning us processing your personal information;

If you also want to learn more about the use of cookies and other technologies related to your use of the website, please see our Cookie Policy.

From time to time we make changes to this Policy. This may be in relation to changes in the law, best practice, changes in our services or treatment of your personal information. Where necessary, we will notify you of these changes. We will always display clearly when the privacy policy was last amended on the website.

1. What personal information we are processing, why and on which legal basis

1.1 Processing related to general interactions with us

Billing & administration — For any payable service, we will use the personal information that you provide us with to invoice you. We will also use that personal information to maintain an up-to-date administration. This processing activity is necessary to perform the contract with you (invoicing) and to comply with a legal obligation (keeping an administration).

Contact with you — When you contact us, e.g. through one of the contact forms on our website, if you call us for support, we contact you, e.g. to inform you about certain updates, or in case we have ongoing business with each other, we use your personal data for our ongoing business and to answer your requests, e.g. provide you with support. The legal basis for this processing activity is that we either have a contract with you, or that we take steps at your request prior to entering into a contract.

Due diligence, security of our offerings and preventing fraud – As we aim to provide you with products and services that are most secure and as we want to keep our people and business safe, we have a legitimate interest to use your personal information to conduct due diligence investigations, to maintain the security of our offerings and to prevent fraud.

Legal purposes — Sometimes we need to use your personal information to handle claims, to comply with applicable laws or law enforcement requests. This processing activity is in our legitimate interest, or to comply with a legal obligation.

Marketing and promotions — If you have consented to receive communications from us, or if you are an AEV Charging INC partner or customer, we may contact you for the promotion of our own similar products and/or services, to invite to events we may organize, and to inform you about latest news and updates. The legal basis for this processing activity is either your consent, or our legitimate interest. You can easily opt-out of this service by clicking the unsubscribe button provided in our promotional emails or contacts our official email in @aevcharging.com.

Online surveys — At times we may ask you to participate in a survey that allows us to improve our offerings. In such case, we use the information you provide us only for that purpose, and we might share it with our survey partner for the same purpose.

Quality improvement — Log-files of connected charging stations contain valuable information for us to improve the quality of our offerings. We use the information contained in those log-files for that purpose. The personal information that we process for this purpose are service data of charging stations that are connected to our platform and charging sessions of EV-drivers that use such charging stations within the AEV Charging INC network. The legal basis for this processing activity is that it is in our legitimate interest, because we aim for constant improvement of our offerings and to that extent, it is critical for us to have the opportunity to use these statistical data.

Recruitment and onboarding – If you apply for one of our positions, we process your personal information to assess if you are suitable for such position. The legal basis for this processing activity is that it is in our legitimate interest, as we need to assess how you can help us to accelerate the transition towards a zero-emission future. The personal information that we process for this purpose:

• Background check information from public authorities;
• Character and/or performance information from referees;
• Pre-employment assessment information from assessment service providers;
• Personal information from the public section of your social media account(s), or other public information about you; and
• Personal information that you provide us with.

We will only use the personal information about you if such is necessary and relevant to the position you apply for.

In the application process we will ask you if we can also contact you for any upcoming employment opportunity for which you may be suitable, and thus keep your personal information on file for a period of one year. You can refuse and/or withdraw your consent at any time.

In case your application is successful, we have a legitimate interest to continue to process your personal information so that we can make you an offer, and subject to your acceptance, enter into an employment relationship with you and welcome you aboard.

1.2 Processing related to our EV charging solutions

Account management — When you set-up an account with us, for example on our Software application, we use the personal information you provide us with to set-up and maintain your account; this is necessary to perform the contract with you. If you have opted to make your GPS location visible on the map, we process this personal information based on your consent.

Charging at a public charging station using an AEV Charging INC charge card 

+- If you have enabled roaming in our software application (=service where you can charge with an AEV Charging INC charge card at public charging stations connected to the AEV Charging INC network), we process the following personal information:

• A unique charge card number;
• A unique charging station number;
• Details about your charging session; and
• Location of the charging station where you charged.

This processing activity is necessary to perform our contract with you.

Charging at your own AEV Charging INC charging station – Our charging stations are in principle connected stations, allowing us to provide you with additional services & support and are delivered with an AEV Charging INC charge card. Subject to you registering your AEV Charging INC charging station on our platform, we will process the following personal information for this purpose:

• A unique charge card number;
• A unique charging station number;
• Details about your charging session;
• Location of your charging station;
• Log files containing service data of your charging station and charging sessions; and
• Personal information that you register on our platform.

This processing activity is necessary to perform our contract with you.

If the charging station is not connected, we do not process personal information.

Charging at an AEV Charging INC charging station using another eMSP’s charge card — If you hold a charge card of another eMobility Service Provider (“eMSP”), allowing you to charge at an AEV Charging INC charging station, we process the following information:

• Authenticationnumber;
• A unique charge card number;
• Details about your charging session;
• Location of the charging station where you charged;
• NameofeMSP; and
• Transactionnumber.

This processing activity is necessary to perform a contract to which you are a party (the one you have with your eMSP). Your eMSP has its own purposes for processing your personal information; please contact them if you want to know more.

AEV Charging INC offerings – If you leave us, or one of our business partners leaves us your personal information (via website, e-mail, phone, in person or any other means) because you are interested in our products and/or services, we store your request and use that personal information to reach out to you, so that we can supply you with a quotation for the products and/or services of your interest.

The legal basis for this processing activity is that we take steps at your request prior to entering into a contract, or your consent.

We may transfer this information to one of our business partners, if we deem this partner can better service you; in this case your personal information is processed under this business partner’s privacy policy.

Purchasing an AEV Charging INC charging station or accessory – We use the personal information you provide us with to deliver the product and, if part of our agreement, to provide associated services (e.g. installation). We might share this information with business partners we use for the performance of these services. This processing activity is necessary to perform our contract with you.

Registering your AEV Charging INC charging station and/or charge card — Registration is necessary so that we can provide you with the agreed charging management service(s). The personal information that we process for this purpose:

• A unique charge card number;
• A unique charging station number;
• Location of your charging station;
• Log files containing service data of your charging station and, in case of roaming, charging sessions of EV-drivers that use your charging station; and
• Personal information that you register in our platform.

This processing activity is necessary to perform our contract with you.

Warranty and maintenance services — We use the following personal information to provide with you any kind of warranty and/or maintenance services:

• A unique charge card number;
• Commissioning reports provided to us by one of our independent service partners that has serviced you on our behalf;
• Location of your charging station;
• Log files containing service data of your charging station and, in case of roaming, charging sessions of EV-drivers that use your charging station; and
• Personal information that you provide us with by any means, for example if you call or email us.

We use a network of independent service partners, so we may forward your request to the applicable service partner.

Additionally, we use your charging station number to provide you with regular firmware updates to keep your charging station secure.

This processing activity is necessary to perform our contract with you.

2. Who do we share your personal information with?

AEV Charging INC is a company that operates on a global level and we may have a legitimate interest to share personal information with affiliate companies.

We also use trusted service providers to provide certain services for us in relation to the processing of your personal information. For example, we store personal information with an external hosting provider and we use a payment service provider to facilitate ad-hoc payments.

In addition, we may share your personal information with our business partners, for example your eMSP if you charge at an AEV Charging INC charging station with your eMSP’s charge card, a support service provider who manages service incidents, or a reseller to follow-up on your request for information on our products.

Finally, to the extent we are required by law, regulation or court order, we may disclose your personal information in compliance with that law, regulation, or court order.

3. International transfers

We may transfer your personal information to a third party that is located outside the US. If this country does not provide for an adequate level of protection under its domestic law, we have ensured this adequate level of protection by agreeing on additional appropriate safeguards with a third party through the Standard Data Protection Clauses adopted bythe EU-U.S. Privacy Shield.

Alternatively, we may ask you for your explicit consent to the proposed transfer. You may request a copy of the Standard Data Protection Clauses by sending us motivating your request.

4. For how long do we keep your personal information?

Where possible, we have set specific retention periods for keeping your personal information. These specific retention periods are stated below, or we shall communicate these to you at or before we start processing your personal information.

Where it is not possible for us to use set retention periods, we have stated below the criteria that we use to determine the retention periods.

Specific retention periods

Billing & administration for any of our offerings – we keep your personal information that is required to be kept by law for maintaining an administration for a period of 7 years, or longer if so required by local law.

Marketing & promotions — We keep your personal information for as long as you are subscribed, or until we cancel our newsletter service, whichever occurs first. You can easily opt-out of the newsletter by clicking the unsubscribe button provided in the email.

Recruitment & onboarding — In case the job application is successful and we can welcome you aboard, we shall store your personal information in our personnel files, which we shall keep in accordance with our data protection policy retention times.

In case the job application is unsuccessful, we shall keep your personal information for a maximum of four weeks after the job application process has ended.

In case you consent to us keeping your personal information for future opportunities, we shall keep your personal information for a maximum of one year after the job application process has ended.

Criteria for determining retention periods

In any other circumstances, we use the following criteria to determine the applicable retention period:

• The assessment of your fundamental rights and freedoms;
• The purpose(s) of processing your personal information. We shall not keep your personal information longer than is necessary for the purpose(s) we collected it for;
• Any relevant industry practices or codes of conduct on keeping personal information;
• The level of risk and cost associated with keeping your personal information (accurate and up-to-date);
• Whether we have a valid lawful basis to keep your personal information;
• The nature, scope and context of processing of your personal information and our relationship with you;
• Any other relevant circumstances that may apply.

In any case, we shall keep your personal information in compliance with applicable law and make periodical reviews of the personal information held.

5. Your rights concerning our processing of your personal information

You have certain legal rights that we wish to inform you of.

Access. You have the right to be informed on whether we process your personal information or not and to related information on that processing.

Consent withdrawal. If you have supplied us with your personal information based on your consent, you have the right to withdraw such consent at any time. You may withdraw your consent by unsubscribing from the service that you have subscribed to if applicable. You may also do so by sending us a request on website to our security expert. We shall then permanently remove your personal information from our database.

Data portability. We are required to inform you of your right to receive your personal information from us so that you can transmit that personal information to another service provider.

Control over data matching. If you would like to opt out of data matching with our commercial partners, please contact us. You will need to provide us with relevant information in order to identify you.

Lodging a complaint. You have the right to lodge a complaint with a supervisory authority, in particular in the country of your residence, about our processing of your personal information. You can find a complete list of supervisory authorities for US here, UK  here or EEA here.

Rectification. You have the right to have your personal information corrected or completed by us without undue delay. If you have set up an account with us, you may have the possibility to correct or complete your personal information yourself.

Restriction of processing. You have the right to request that we restrict the processing of your personal information based on specific grounds. These are (1) the time for us to verify the accuracy of your personal information on your request; (2) instead of erasure of unlawful processing, you request restriction of use instead; (3) we no longer need your personal information, but you need this personal information in legal proceedings; or (4) we are verifying whether our legitimate grounds override your objection to the processing.

Right to be forgotten. You have the right to have your personal information erased by us without undue delay. This right is limited to specific grounds, for example if you have withdrawn your consent, or if you object and there are no overriding legitimate grounds for us to maintain the processing. If you have an account with us, in some instances you have the option to erase your account yourself, in which case all your personal information is permanently deleted.

Right to object. You have the right to object at any time to our processing of your personal information if such processing is (1) based on our legitimate interest (including us making a profile of you based on your consent); (2) for direct marketing purposes; or (3) necessary for the performance of a task carried out in the public interest or exercise of official authority vested in us. We shall cease to process your personal information based on your objection, unless we demonstrate compelling legitimate grounds overriding your interests, rights and freedoms.

«DO NOT TRACK» browser settings. If you choose to turn on the «Do Not Track» setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to request that they stop tracking your activity. Currently our websites and apps are not designed to respond to «Do Not Track» signals.

Stopping browser pop-up notifications. If you have pop-up notifications enabled on your desktop, you can use the following instructions to opt out.

Google Chrome
Click the 3 dots at the top right > Select settings > advanced > privacy and security > content settings > notifications > click the three dots next to the websites that are in the “allowed” category > click Remove.

Safari
Choose Safari > Preferences, click Websites, then click Notifications > Find the website in the list, then select Deny.

Safari
Choose Safari > Preferences, click Websites, then click Notifications > Find the website in the list, then select Deny.

Firefox
Click the menu button and select Options > Select the Privacy & Security panel and go down to the Permissions section > Click the Settings using the button next to Notifications > Select the website > Click Remove Website.

Microsoft Edge
Click the three dots button in the top-right of the browser window > Click settings > Click View advanced settings > Under Notifications, click Manage.

CALIFORNIA RESIDENTS

California ‘SHINE THE LIGHT’ law. Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us.For all requests, you must put the statement «Your California Privacy Rights» in the subject field of your request and include the name of the data controller (listed in the ‘About Us’ section) to which you are requesting the information. You must also include your name, contact details, address and other identifiers that will help us locate your information.

California consumer privacy act. The California Consumer Privacy Act of 2018 («CCPA») provides certain rights to residents of California. This section of our Policy applies if you are a resident of California («California Consumer») and use our products or services. Certain terms used below have the meanings given to them in the CCPA.

Categories of personal Information we collect about you, why and how. Summarised in the table below are the categories of personal information we may collect about you over the past twelve (12) months, depending on how you interact with us. The following table also describes how we collect and use such categories of information.You can find further information about the categories of personal information we may have collected about you, as well as the method of collection are set out in the ‘Collection of Your Information’ section of this Policy. The precise categories collected and purposes used will depend on which of our products and services you interact with.

Categories of Personal Information Collected:

• Identifiers (such as your contact information (name, email address), unique personal identifiers (such as device ID, cookies, IP address) («identifiers»)
• Commercial information (such as transaction data, viewing history or purchase history) («Commercial Data»);
• Financial information (such as credit card information)(«Financial Data»);
• Internet or other network or device activity (such as browsing history or app usage) («Internet Data»);
• Geo-location information («Geolocation Data»);
• Biometricinformation («BiometricData»);
• Sensory information (such as audio or visual information)(«Sensory Data»);
• Inference information about you («Inference Data»);
• Legally protected classifications (such as gender, race, marital status)(«Protected Data»);
• Physical characteristics or description («Physical Data»);
• Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviors, attitudes)(«Profile Data»);
• Information that identifies or can be reasonably associated with you («Associated Data»).

We do not knowingly collect or use the personal information of consumers under the age of 18.

California consumer rights & choices. California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

The right to access and disclosure — You may have the right to request, twice during a twelve month period, the following information about the personal information we have collected about you during the past 12 months:

• the categories and specific pieces of personal information we have collected about you;
• the categories of sources from which we collected the personal information;
• the business or commercial purpose for which we collected or sold the personal information;
• the categories of third parties with whom we shared the personal information; and
• the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

The right to deletion — you may have the right to request that we delete the personal information we have collected from you.

Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

Authorised agents. You may designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorised to make a request on your behalf through providing us with a signed written authorisation or a copy of a power of attorney

Any questions or feedback for us?

We welcome all questions, comments, and concerns about our privacy policy and privacy practices. Please use the Talk to an expert form to submit any questions or concerns, or if you wish to exercise your rights related to your personal data.